ITG FAQ #12 Answer-What is the effective date of IRC section 7873?

The provisions of IRC section 7873 apply to all taxable years beginning before or after the date of enactment (11/10/88), but only to the extent that the statute of limitations for assessment has not expired. Thus, all taxes with respect to which the statute of limitations has not expired may be subject to claims for refund.

Note: Regardless of the statute of limitations, no amount of tax, penalty, or addition to tax will be collected from a taxpayer to the extent the underlying deficiency is attributable to income derived from fishing rights-related activity that is exempt from tax under the provisions of IRC section 7873.